Privacy Policy
Last updated: July 24, 2026
This Policy explains how SP10 DOO NOVI SAD collects, uses, retains, and protects data relating to visitors of pogon.dev.
1. Data controller
The data controller is SP10 DOO NOVI SAD, Stanka Paunovića 10, 21000 Novi Sad, Serbia, company number 21075027, tax ID 108825672. Privacy inquiries: privacy@pogon.dev. Referred to below as “Pogon”, “SP10”, “we”, or the “controller”.
2. Scope
This Policy applies to the publicly available pogon.dev website and communication through the published contact email address. Individual applications may have separate privacy policies once publicly available or when they process additional categories of data.
3. Data we process
3.1. Data you provide
When you email us, we may process:
- your name
- organization, if provided
- email address
- message content
- subsequent correspondence
- other information you voluntarily provide
3.2. Technical data
Cloudflare infrastructure and security systems may process limited technical data to operate and secure the site.
- IP address
- access date and time
- requested page or resource
- browser, device, and operating system
- HTTP headers and user-agent
- approximate location derived from IP
- response status, performance, error, and security-event data
4. Purposes and legal bases
4.1. Responding to inquiries
We use contact data to understand and answer your request, prepare a call or meeting, and take steps at your request before a potential engagement. The legal bases are pre-contractual steps and our legitimate interest in business communication.
4.2. Business communication
If communication continues, we may use data for negotiations, proposals, meetings, contracts, and records of business correspondence, based on pre-contractual steps, contract performance, or legitimate interests.
4.3. Site operation and security
Technical data is processed for availability, content delivery, abuse and attack prevention, diagnostics, and performance, based on our legitimate interest in a secure and reliable website.
4.4. Legal obligations and claims
We may process data to comply with law, respond to lawful authority requests, prevent abuse, or establish, exercise, and defend legal claims.
5. Required information
Sending an email is voluntary. Without contact details and sufficient information about the inquiry, we may be unable to understand or respond to it.
6. Recipients and service providers
Data is available only to authorized SP10 personnel and, where justified, infrastructure and email providers, technical support, professional advisers, and competent authorities.
Cloudflare
The site is hosted and delivered through Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA. Cloudflare provides hosting, DNS, CDN, TLS, and network and application security. It may process IP addresses, request, device, browser, and security-event information as needed to provide and protect the service, acting as a processor for this activity.
7. Contact by email
The site does not contain a contact form and does not transmit inquiry content through its own API route. Clicking contact@pogon.dev opens the user’s email application. Transmission is handled by the user’s email provider and SP10’s business mailbox provider, whose identity is not exposed by or identifiable from the website.
Messages received in the mailbox are retained as business correspondence. Contact data is not used for newsletters, advertising, or automatic marketing enrollment.
8. International transfers
Cloudflare operates a global network, so technical data may be processed outside Serbia, including in the United States and locations where Cloudflare or its subprocessors operate. Transfers are subject to appropriate contractual, organizational, and technical safeguards. Contact privacy@pogon.dev for information about safeguards relevant to a specific transfer.
9. Retention
We retain data only as long as necessary for its purpose.
- inquiries that do not lead to an engagement: up to 24 months after the last communication
- engagement data: during the relationship and afterward as required for contracts, law, and legal interests
- technical and security data: according to the active Cloudflare service and configuration, only as needed for security and diagnostics
- security-incident data: longer where necessary for investigation or legal protection
- legally required records: for the applicable statutory period
10. Cookies and tracking
We do not use advertising, profiling, or marketing-tracking cookies. We do not use Google Analytics, Google Tag Manager, Meta Pixel, Hotjar, Microsoft Clarity, or similar tools. Cloudflare may use only technically necessary mechanisms for network and application security. No cookie-consent banner is required for the current configuration.
11. Network and application protection
The site uses general Cloudflare network and security features to protect against attacks, unwanted traffic, and abuse.
12. Automated decision-making
Public-site data is not used for automated decisions that produce legal or similarly significant effects. We do not profile visitors.
13. Your rights
Subject to applicable law, you may request access, correction, deletion, restriction, and applicable portability, or object to processing based on legitimate interests. You may complain to the competent authority. Send requests to privacy@pogon.dev; we may request identity verification to protect your data.
14. Complaint to the authority
You may complain to the Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia if you believe processing is unlawful. You may first contact privacy@pogon.dev so we can try to resolve the matter.
15. Data security
We use reasonable measures including HTTPS and TLS, Cloudflare network protection, access controls, software updates, secure secret management, incident response, and data minimization. No transmission or storage method is absolutely secure.
16. Children
The site is intended for business users and adults. We do not knowingly collect children’s data and will take reasonable steps to delete it if provided without a valid basis.
17. External links
We do not control external sites and are not responsible for their privacy practices, security, or content. Review their privacy policies before providing data.
18. Changes and contact
We may update this Policy to reflect operational, technological, or legal changes. The current version and update date will remain available here.
Privacy inquiries: privacy@pogon.dev. SP10 DOO NOVI SAD, Stanka Paunovića 10, 21000 Novi Sad, Serbia. Company number 21075027, tax ID 108825672.